🛢️ DAYTONA 6-5-4 4H

Devon Energy Williston, LLC · Williams County, ND · File #42689 · Generated 2026-02-13 12:33

API: 3310506794
Target Formation: Bakken
Permit Explained: Partially

📋 Permit Cycle Assessment

The permit file contains direct regulatory conditions (Commission Order No. 34514, pool definition, setback requirements) that frame the approval, but lacks explicit permit approval documentation or reasoning letter from NDIC. The technical justification for the non-routine 150' east setback is provided in the Bakken Setback Summary Statement (wet shoe design with frac-out capability). The contemporaneous Backbuild Order Waiver letter (January 28, 2026) explains the regulatory pathway for well geometry that traverses an adjacent spacing unit, but this letter post-dates the permit approval date (July 5, 2026 dirt work date; permit issuance date missing). No explicit NDIC approval letter, geologist requirement, or permit synopsis explaining why this specific setback geometry was approved is present in the file. The stipulations themselves condition the approval but do not explain its issuance.

🔍 Permit Cycle Signals (4)

Commission Order No. 34514 conditional approval tied to well-bore setback geometry (500' north/south, 150' east/west from 1920-acre spacing unit boundaries)

Direct

📄 Permit page 1, NDIC Field Order Info stipulation
📅 Unknown (Missing confidence)

Setback approval is the direct regulatory condition enabling this specific well geometry. The 150' east setback is explicitly justified by production liner design with wet shoe and frac-out capability.

Bakken Setback Summary Statement: East setback based on production liner cemented in lateral with wet shoe and ability to frac out shoe

Supporting

📄 Permit page 1, Bakken Setback Summary Statement stipulation
📅 Unknown (Missing confidence)

Technical justification for non-standard setback reduction (150' vs. standard larger setbacks). Wet shoe design directly conditions the regulatory approval and differentiates this from routine horizontal approvals.

Pool definition: Painted Woods-Bakken Pool defined as interval from 50 feet above top of Bakken to above top of Birdbear Formation

Direct

📄 Permit page 1, NDIC Field Order Info (pool definition)
📅 Unknown (Missing confidence)

Establishes regulatory pool boundaries within which the well must operate. Required for permit validity but routine to Bakken horizontal drilling.

Backbuild Order Waiver letter (January 28, 2026): Devon self-notifies that well bore will traverse adjacent spacing unit; Devon is operator of adjacent unit, therefore no third-party notification required per NDIC Order 31973

Supporting

📄 January 28, 2026 letter to Todd Holweger (Permit Manager), subject line references waiver of adjacent spacing unit notification requirement
📅 2026-01-28 (Exact confidence)

Demonstrates contemporaneous compliance action. Well geometry (ITP at 550' FSL, 150' FEL; BHL at 550' FSL, 150' FEL per coordinate table) triggers backbuild trajectory that enters adjacent spacing unit. Waiver letter pre-dated actual drilling (January 2026, permit approved 07/05/2026) but confirms regulatory pathway for this non-routine geometry.

📖 Historical Context (3)

North Dakota Department of Mineral Resources filter sock disposal directive (May 30, 2025): Leak-proof container requirement effective June 1, 2014 for all wells spud in North Dakota
📄 DMR letter dated May 30, 2025, addressed to oil and gas operators statewide · 📅 2025-05-30
Operational requirement persisting through drilling, completion, and flow-back phases. Affects waste management logistics and cost on this pad and future operations. Not specific to Daytona 6-5-4 4H but applies to all Devon operations in North Dakota.

Construction commencement notification requirement: Devon must contact NDIC Field Inspector Jessica Gilkey (701-770-7340) prior to location construction
📄 Permit page 1, Construction Commencement Notification stipulation · 📅 Unknown
Pre-construction notification condition that must be satisfied before pad development begins. Ties regulatory oversight to physical site preparation phase.

Comingling of Production (CPF) authority: Director has discretion to approve consolidation of production equipment at central location
📄 Permit page 1, CPF stipulation · 📅 Unknown
Enables future operational flexibility for multi-well pad commingling if approved; also subjects future changes to regulatory gate.

🔧 Operator Pattern

Devon operates Bakken spacing units in T154N, R102W (Williams County) and holds adjacent acreage. Multi-well pad development (4 horizontal wells from single surface location in Lot 6, Section 6) consistent with efficiency-focused Bakken strategy.
Backbuild waiver letter identifies Devon as operator of both the subject spacing unit and adjacent unit. Well location plats show four wells (Daytona 6-5-4 1H, 2H, 3H, 4H) from single Lot 6 pad with coordinated ITP and BHL positions. Coordinate table and survey documentation (by Thomas E. Osen, LS-7965) indicates professional survey standards and locational discipline.

Confidence: Medium
Permit stipulations and technical justifications (wet shoe design, setback summary) are clearly documented and explain non-routine setback reduction. Backbuild waiver letter provides regulatory pathway explanation. However, critical gaps exist: (1) No NDIC approval letter or synopsis explaining permit issuance decision; (2) Permit approval/issuance date missing (only dirt work date of 07/05/2026 provided; unclear if permit was issued before or after); (3) Backbuild waiver letter dated January 28, 2026 appears to post-date or be contemporaneous with approval, introducing ambiguity on whether it was a pre-approval submission or post-approval compliance document; (4) OCR quality on survey/plat pages may have missed ancillary conditions. Pool definition and setback geometry are well-documented and defensible, but the permit approval record itself is incomplete.